Tax Articles

8 04, 2021

Tax Provisions in the American Rescue Plan Act of 2021

2021-04-08T02:25:12+00:00April 8th, 2021|Tax Articles|

On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”), a $1.9 trillion economic stimulus package and comprehensive COVID relief bill that provides a wide range of assistance to businesses and individuals. As with the COVID-related Acts preceding it, ARPA facilitates much of this assistance through changes to the federal tax code. This blog Continue Reading

17 03, 2021

Section 1061’s Application to Real Estate Carried Interests (or Not)

2021-03-18T00:00:26+00:00March 17th, 2021|Tax Articles|

Persons interested in investing in real estate may not have the capital to purchase or develop real estate. Ordinarily those persons will seek out investors to provide the capital, while retaining a profits interest in the venture (a “promote” in the real estate world) in exchange for managing and facilitating the venture. A promote held by such a service partner is Continue Reading

3 03, 2021

You Can Leave California (With the Right Facts)

2021-03-03T23:51:25+00:00March 3rd, 2021|Tax Articles|

This post follows up on an earlier post from December 12, 2020, titled “The Long Arm of California’s Franchise Tax Board.” That post described a recent opinion by California’s Office of Tax Appeals (OTA), Appeal of L. Mazer and M. Mazer, in which the OTA ruled in favor of the Franchise Tax Board (FTB), holding that the taxpayers were California Continue Reading

18 02, 2021

Final Regs Defining ‘Real Property’ for Section 1031: IRS Gets It Right With ‘State Law Plus’

2021-02-18T00:25:09+00:00February 18th, 2021|Tax Articles|

Jon Christianson and Matthew Carlson of Boutin Jones Inc., together with Louis Weller of Weller Partners, LLP, and Richard Lipton of Baker & McKenzie, LLP, were co-authors of an article that was recently published in the February 2021 issue of the Journal of Taxation titled, “Final Regs Defining ‘Real Property’ for Section 1031: IRS Gets It Right With ‘State Law Plus.’”  Continue Reading

4 02, 2021

Opportunity Zones: Further Extensions in the Land of Oz

2021-02-04T23:07:57+00:00February 4th, 2021|Tax Articles|

Good news from the Land of Oz: on January 19, 2021, the IRS issued Notice 2021-10, which extends the relief granted to qualified opportunity funds (“QOFs”) and their investors in previous Notice 2020-39. Notice 2021-10 (the “Notice”) extends due dates until either March 31, 2021 or June 30, 2021, in response to the continued challenges posed by the coronavirus pandemic.

The Notice Continue Reading